Wealth-tax valuation procedure under Schedule III applied to pending assessments, displacing rule 1BB for earlier years.

Schedule III of the Wealth-tax Act, introduced from 1 April 1989, was treated as a procedural valuation method and applied to pending assessment proceedings for earlier years. Because it was procedural rather than substantive, it governed assessments for 1985-86 to 1988-89, and rule 1BB of the Wealth-tax Rules did not bar its application. The Tribunal was therefore correct in holding that the reference question need not be made under section 27(1).

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Issues: Whether Schedule III of the Wealth-tax Act, inserted with effect from 1 April 1989, applied to assessment years 1985-86 to 1988-89, or whether valuation had to be made under rule 1BB of the Wealth-tax Rules.

Analysis: The dispute related to assessments for years prior to 1 April 1989. Schedule III was treated as laying down a procedural method for valuation rather than creating a substantive right. On that basis, the valuation procedure introduced by Schedule III was held applicable to pending matters, and the earlier rule 1BB did not prevent its application. The rejection of the reference application under section 27(1) was therefore found justified.

Conclusion: Schedule III applied to the pending valuation proceedings, and the Tribunal was correct in refusing to refer the question.

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